DAG Meeting 8th May 2019

Premier League Disability Advisory Group (DAG)

 Meeting 8th May 2018

 

Venue: Liverpool Football Club’s Anfield Stadium

Guests and Premier League Attendees :-
Simon Thornton        
Liverpool - Diversity & Inclusion Manager
Lorna Duckworth       Liverpool
Dean Eales                AccessAble
Peter Kay                   
Premier League Consultant

DSA Attendees :-
David Butler                DSA Chair      DAG Chair        Watford
Chas Banks                DSA Chair                                Manchester United
Mark Barber                DSA Secretary                         Manchester City
Peter Carr                   DSA Chair                                Tottenham
David Higham             DSA Chair                                Liverpool
Steve Daniels              DSA Chair                                Wolves
Andy Mather                DSA Chair                                Southampton
David Smith                 DSA Chair                                Crystal Palace
Cathy Bayford              DSA Co-Chair                          West Ham
Trevor Bright                DSA Co-Chair                          West Ham
Kevin Holden               DSA Chair                                Burnley
Carol White                  DSA Membership Secretary    Burnley
Sandra Fixter               DSA Chair                                Leicester
Stephen Miller              DSA Secretary                         Newcastle
Phil Dewick                  DSA Chair                                Sheffield United
Janet Ireland                SUDS Secretary                      Sheffield United
Kevin James                DSA Vice Chair                        Norwich

Apologies
Bill Bush                       Executive Director                    Premier League
Katherine Allen            Policy and Supporter Relations Premier League
Anthony Joy                 DSA Chair                                 Arsenal
Dave Heatherill            DSA Chair                                 Huddersfield

David Butler - Chair’s Report  - Please find this at the end of this document.

Accessible Stadia Guidelines –

1)      Revision discussion

The meeting agreed that the items for revision of the ASG’s, identified in the three-page summary (copied at the end of these minutes), reflected the key areas which would enhance the match day experience of our ambulant members.

Given that it has been accepted that the ASG is in need of review and update the Group will offer to be heavily involved.

David B to inform and discuss with SGSA and PL.                                                    Action:  David B


2)      Hospitality calculation document

The meeting considered the three calculation options in the SGSA document entitled “Wheelchair accommodation in stadium considering the effect of hospitality provision”.

David B added that any recalculation must also be applied to ambulant disabled accommodation.

In presenting the document David B added a fourth option – that the wording remain unchanged and that any disabled hospitality provision should not be included in the Table 4 quota.

This proved a contentious area. Concern was expressed that any change that included hospitality disabled provision against a Table 4 commitment would lead to a reduction in General Area(GA) numbers particularly when hospitality operations are being expanded at most clubs. Another minority view was that if hospitality numbers were not included we would be seen to not be supporting disabled fans in the hospitality areas.

It was pointed out in the paper that by law all areas of the stadium are bound by the ASGs whether they are counted or not under Table 4.

Quote from the ASG Supplementary Guidance 2015 – Section 4. VIP and hospitality suites

All areas of the stadium, including the VIP and directors boxes and corporate and hospitality suites, should be access at all to disabled people, along with any adjoining facilities and amenities. As such, inclusive design principles should be used in these areas and improvements should be made where required to ensure equal access. Wheelchair user spaces and amenity and easy access seating located in hospitality areas should not be included in the quota general seating areas but should be provided additionally”

It was also felt that when demand from disabled supporters for hospitality positions did not materialise, due mainly to the expense of such packages, these positions would be converted for able-bodied fans but still counted against the clubs Table 4 commitment.

The meeting approved Option 4: No change to current wording.

David B to respond to SGSA and PL with this decision.                                                Action: David B

 

ASGs  - Promotion and Relegation - NB: The Paper presenting these proposals can be found at the end of these minutes.

1)      Proposal : Given sufficient notice; in future years Championship clubs should be ASG compliant before they are accepted for promotion to the Premier League or face a points sanction. 

There should not be any period of grace thereby forcing prior implementation of improvements.

Concern was expressed over facing a points deduction should they not be ASG compliant however as there appeared to be no other effective sanction this proposal was approved.

2)      Premier League clubs regaining promotion

Proposals -

1)         Premier League Clubs that are relegated and who were original signatories to ASG commitment should not be permitted to return to the Premier League or face a severe points sanction if they have not honoured that commitment. The “period of grace” clock should not stop after one year and restart upon promotion as is currently the case.

2)         Promoted clubs that have remained in the Premier League for a two year period having then suffered relegation should not be permitted to return to the Premier League or face a severe points sanction if they have not fully honoured their ASG commitment. 

3)         Should a team immediately bounce back from relegation the following season they should not receive any further period of grace given the substantial parachute payments they will have received.

All proposals approved

The meeting felt that any club being relegated regardless of the how long they have been in the Premier League, even just one year, should be subject to Proposal 3 below.

3)       Proposal from the floor:- Relegated Premier League clubs

Premier League clubs relegated in the future should be subjected to an extensive audit against their ASG commitment. If they are found not to be fully compliant, the outstanding compliance work should be costed and this sum “ring fenced” and withheld from their first year parachute payment.

Proposal approved.

As the Chair commented - Let’s be honest  - the expenditure to complete the necessary work is probably significantly less than the cost of the lower leg of a good striker!

Agreed proposals to be submitted to PL for comment                                         Action: David B

 

Away questionnaire continuation?

It appeared that many clubs had only just got started with the questionnaire towards the end of the season so it was decided to clear all the current data out of the system (or archive it if possible for future comparisons) and Mark will then reset it for next season. He will adjust for promotion and relegation plus initially offering a test questionnaire for the new club’s end users to try it out.

The questionnaire and all the links for individual submissions and summaries will be on our website just prior to the season commencing.                                                                                                                                                                                                                                                           Action: Mark

Away Supporter Ticketing Communication – Discussion with AccessAble

Dean Eales from AccessAble explained that they were a “not for profit” organisation and were contracted by the Premier league to include detailed information about each Premier League club on their website. Dean gave a presentation, using Liverpool Stadium as the example, illustrating the extensive data and information currently available on their website and how to access it.

Dean agreed he would send a list of Premier club links for David to circulate and for those DSAs that have their own websites to publicise their link and also check the data contained and feedback to Dean on any inaccuracies and suggested additional information.

                                                                                                           Action: Dean, David B and DSAs

Disabled Supporters Attendance Statistics     Utilisation of current facilities     Waiting lists

David B again stated, as he has for the last two meetings, that the Premier league clubs will not share with the DSAs the statistics to enable an understanding of the utilisation of disabled facilities or the extent of their waiting lists. It is considered sensitive information which is why we want it!

David B to suggest that the Premier league should themselves request this important data and publish it.

Action: David B

 

Discussion ensued as the qualification of the disabled supporter to gain a free carer ticket. Again, a recurring problem, the recognition of wide discrepancies covering what each club will accept as evidence of disability.

The Group felt this should be regularised across all clubs. It was agreed to put that position to the Premier league.                                                                                                                                   Action: David B

Issues surrounding assessment & insurance of Assistants / Carers

Each club appears to interpret this issue independently, to an extent understandable, as it is a liability concern interpreted by individual insurance stadium policies. It is a current issue at a number of clubs. We understand that the Premier League DLO meeting has this on their agenda, if this is so we will ask for feedback.

The meeting felt that this issue may only be resolved when an incident results in a legal case.

 

Pitchside Advertising – Flashing imagery

Kevin Holden explained the concerns around the use by Astropay of pitch side flashing imagery, used at Burnley and Chelsea grounds, and the potential adverse impact upon some epileptics. He made a complaint to the Advertising Standards Agency who agreed such imagery contravened their regulations and the signs were immediately removed.

The ASA information has been circulated to all Premier league clubs.

The meeting thanked Kevin for his prompt and successful action.

DAG Constitution, Election of Officers, Tenure etc

It was agreed that a draft constitution should be created and circulated together with job roles for the Chair and Vice-Chair (plus any other future officers envisaged). In the interim, and assisting with this task, Peter Carr was elected as Vice-Chair pending the agreement and signoff of the above.

                                                                                                          Action: Peter +  Small sub group?

Overall comment - What came out throughout the day on so many issues, was the degree of inconsistency in rules and interpretation amongst the Premier League clubs.

David B thanked everyone for attending today and for their contribution and closed the meeting at 4pm

Liverpool football club then invited the Group to view the impressive stadium facilities.

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PL DAG Chair’s Report – 8th May 2019

Firstly may I think you for my unanimously re-election as Chair.

From a governance point of view it was important and will come back to the requirement for a formal constitution at the end of the meeting.

I was asked by the Premier League to form DAG after they were heavily criticised by the EHRC for having no direct contact with disabled supporters. Since the creation of DAG in February 2018, we have increased both our profile and credibility with our clubs, who appear to be increasingly involving us in dialogue.

I think we have assisted that process by being wholly transparent, publishing minutes and details of our projects on our website. We will continue to do that.

I regret that 4 clubs still do not have a DSA, Brighton who say they have no need or desire although I must say they were very helpful joining the Wembley questionnaire. Bournemouth who have a Cherries Trust with a disabled attendee who has been invited and copied with other documentation. Chelsea have an in-house DSA and they and Everton have not sent representatives.

The good news is that two of the newly promoted clubs have established DSAs and I’m delighted that they are here today – Norwich city and Sheffield United.

If we are now to make real progress we need to continue dialogue individually with our clubs to resolve local issues BUT I believe we have now evolved to the point where we need to determine specific objectives and formulate strategies to achieve them.

I would suggest that our overall objective or mission should be that all Premier League stadia are fully compliant with the Sports Ground Safety Authority’s (SGSA) Accessible Stadia Guidelines.

With regard to the SGSA, I had a productive meeting with Martyn Henderson SGSA CEO and shared with him the 35 page draft revision document which you all have a copy of. Their response stated in writing to me “that SGSA recognises that the current version of the accessible stadium guidance document and supporting supplementary guidance is in need of review and update

I subsequently received input from his group and EHRC and incorporated their suggestions.

For today’s meeting I produced a shortened version with the main points that would, if accepted and implemented, see a significant improvement in our members match day experience. 

This is an opportunity for us to influence change so let’s make the most of it.

The strategy to achieve our objective would be to agree the revisions needed - then present a document to SGSA and the Premier League for discussion.

Changes to the ASG should enhance the match day experience particularly for our ambulant members. I believe we need aim for greater clarity and more detailed specifications so that the stadiums can then be fully and extensively audited against those requirements.   On a personal note I believe those audits need to be extended and conducted on match days and the Audit results published. Transparency!

Should no progress be achieved through these routes then the last resort is to press for legal sanctions implemented via a Stadium Safety Certificates being withheld for non-compliance.  Which is of course what Lord Faulkner and Ian Lucas MP threatened with the “Accessible Sports Grounds Bill” which received a 2nd House of Commons Reading on the 22nd April 2016 causing the 20 clubs to rapidly commit!

Lord Faulkner was insistent that all stadia should be ASG compliant. I will contact him with feedback from our group should no progress be made.

Tactically of course we should continue on a day-to-day basis identifying non-conformance by our own clubs and dealing with those problems locally - particularly with regard to the away issues which we’ve identified as being a real concern. 

I hope the papers I have circulated will begin this process.

One of our existing projects the Away questionnaire, has been seen as a most interesting way of obtaining real feedback. Complimented by both the EHRC and the PL who have been given access to the Summaries.

May I thank Mark for creating the programme and also for his very rapid response to adding an extra survey in response to Wembley Stadium issues.  Initially I logged an “unreasonable adjustment” complaint under Section 20 with Quintain, who own and manage outside the stadium, when my Watford wheelchair members were stuck on a coach for 2 hours at a Tottenham game and other DSA’s reported similar disabled parking and access problems

That extra questionnaire for the four clubs involved in the FA Cup semi-finals received 147 responses across all disabilities from all four clubs.

As a direct result Quintain CEO Angus Dodd, approved treble the number of accessible vehicles for use in future events, not just football, at the stadium. Tom Legg  FA Head of Transport has promised additional improvements that are to be in place at the FA Cup final game. 

On our agenda we have a situation where relegated Premier league clubs who had been original signatories to the commitment to implement the ASG in 2015 have now achieved promotion for next season and but have failed to honour those obligations despite tens of millions of parachute payments.

Norwich and potentially Aston Villa.

To allow them any period of grace to comply, in my view is unacceptable and today we have some proposals to discuss concerning the situation.

A similar concern arises with recently relegated clubs such as Fulham, having not complied while in the PL  - that situation also requires discussion concerning rules for their return in the future.

Of course, it is natural that our individual focus is upon our own stadium and improving the lot of our home fans however given the concerns expressed in the away questionnaire, I would ask you all to be equally concerned for the away section of your grounds to ensure they meet the guidelines.

After all  - our members are visiting each other’s grounds.

Finally, I would like to say how very proud I am of what we have achieved to date and would particularly like to thank all of you for the tremendous help and support I’ve received since the group was formed.

Much appreciated

David J Butler  FCA MBE
Chair - 
Premier League Disability Advisory Group 

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Background Proposals Paper

Paper produced by David Butler  - Chair - Premier League Disability Advisory Group for the DAG Meeting on 8th May 2019

Accessible Stadia, Facilities for Disabled Fans

The Accessible Stadia Guidelines were published in 2003 “A good practice guide to the design of facilities to meet the needs of disabled spectators and other users” followed by the SGSA Green Guide and the Accessible Stadia Supplementary Guidance in 2015. 

In September 2015, the 20 Premier League clubs unanimously agreed a resolution to comply with the guidance contained in “Accessible Stadia, Facilities for Disabled Fans” by the beginning of Season 2017/18.

I am writing this paper to express concerns in the implementation of this guidance and to offer proposals to change the enforcement of compliance in future.

All Championship clubs aspiring to be promoted should prepare to be ASG compliant.

The original Premier League signatories were given a two year period of grace to become ASG compliant.  This two year period continues to be offered to the newly promoted clubs from the Championship who were not one of the original signatories.

For certain clubs their attitude in the first year appears to have been “let us wait to see if we stay up”, a similar attitude prevails in the second year during which “we will make some improvements but still see if we survive”.

Most clubs only plan implementation to compliance after promotion, at which point the ground is fully sold out. Prior to promotion the grounds are usually not at capacity and the alterations to meet the Accessible Stadia Guidelines are easier to accomplish given that they are able to move able-bodied supporters to empty areas to accomplish the work to accommodate the disabled fans. 

This would avoid, in subsequent seasons, seat removal and relocation of able-bodied supporters to comply.  There is evidence that this creates a degree of aggravation and hostility towards disabled fans to whom the disruption is often attributed.   

All this is avoidable.

Proposal

Given sufficient notice; in future years Championship clubs should be ASG compliant before they are accepted for promotion to the Premier League or face a points sanction.  

There should not be any period of grace thereby forcing prior implementation of improvements.

_________________________________________________

Premier League clubs regaining promotion

Two Championship clubs currently vying for promotion were original signatories to the Premier Leagues ASG commitment before being relegated - Norwich and Aston Villa. 

Their parachute payments amounted to £90 million for Aston Villa and £74.9 million for Norwich. (source Wikipedia)

Neither club is ASG compliant  - See figures at the end of this document.

I now have to question why any period of grace still remains as a concession to ease the timely implementation of improvements to meet the guidelines.

These clubs have received hundreds of millions from stadium receipts, from the Premier League share of TV income, followed by substantial parachute payments.

Upon their relegation they were presented with the opportunity of less than full stadiums to reconfigure and carry out the compliance work and they have the funds.  There can be no acceptable excuse!

Proposal

1)      Premier League Clubs that are relegated and who were original signatories to ASG commitment should not be permitted to return to the Premier League or face a severe points sanction if they have not honoured that commitment. The “period of grace” clock should not stop after one year and restart upon promotion as is currently the case. 

2)      Promoted clubs that have remained in the Premier League for a two year period having then suffered relegation should not be permitted to return to the Premier League or face a severe points sanction if they have not fully honoured their ASG commitment. 

3)      Should a team immediately bounce back from relegation the following season they should not receive any further period of grace given the substantial parachute payments they will have received.

Let’s be honest  - the expenditure to complete the necessary work is probably significantly less than the cost of the lower leg of a good striker!

___________________________________________

Promoted clubs 2017-18 Season

Hopefully this data is out of date and further unpublicised improvements have occurred.

Little or no reference is made in most Club Access Statements concerning the ASG requirement for 75% of disabled ambulant and wheelchair positions to be elevated!  Therefore this important aspect of ASG compliance cannot be commented upon. 

Neither can the proportionate distribution of disability facilities to away fans be assessed.

Norwich  -

Relegated after 2015-16 season - Original signatory to the Premier League ASG commitment

Wheelchair and accessible toilet deficiency

Ground Capacity  =  27,359

ASG requirement =

 Wheelchairs   171            Ambulant       171      Accessible toilets  - 11

As per a webpage (could not find an Access Statement)

Wheelchairs   84            Ambulant     186      Accessible toilets  10

 

Sheffield United –

Relegate in 2006 – Not an original ASG signatory

 Wheelchair deficiency – Query ambulant number

Ground Capacity  =  32,318

ASG requirement =

 Wheelchairs   186            Ambulant     186        Accessible toilets  - 12

As per a webpage (could not find an Access Statement)

Wheelchairs      83            Ambulant     108         Accessible toilets  ??

 

As per LPF data  -

Wheelchairs      95          Ambulant     186      Accessible toilets  12

 

Potential Play-off contender

Aston Villa  -

Relegated after 2015-16 season -Original signatory to the Premier League ASG commitment –

 

Non compliant in all categories

Ground Capacity  =  42,777

ASG requirement =

Wheelchairs       214        Ambulant    214         Accessible toilets  - 14

Could not find an Access Statement  - LPF website info

Wheelchairs       87         Ambulant     TBC      Accessible toilets 

………………………………………………………………………………………………………………………………..

Main Points for discussion regarding enhancements to the

Current Accessible Stadia Guidelines

 

Home and Away ASG Calculations

Recommended change

Where Stadiums segregate home and away fans, the calculations below are to be applied to ensure that the guideline requirements are achieved for each set of spectators  i.e. compliance to be achieved as if each sector represented a standalone stadium.

The calculation below (Table 4) must be applied to each of these disabled categories:  

1)         Wheelchair positions

2)         Amenity or easy access seating

Where occasional variations to segregation delineation occurs, stadiums should consider incorporating flexible or convertible wheelchair/ambulant seating areas to ensure continued compliance.

The maximum limit pitch side is 25% the remaining 75% must be elevated.  This requirement applies for both wheelchair positions and ambulant spectators and proportionate between home and away supporters.

Currently, Rule 9 of Section R requires that 10% of the accessible spaces in the stadium must be allocated to visiting disabled supporters.

 

Ambulant Disabled

Accessible Stadia Guidelines 2003  -  Extract –

The number of older people in the population is increasing and many of them will have a disability of some kind.

Over the next 30 years (stated in 2003)

The proportion of the population over 65 will increase by 40%

The number of people over 65 will double

The proportion over 80 will increase by 100% and will treble.

There is a correlation between age and disability. Over half the population over 75 has some kind of disability.

Accessible Stadia Guidelines - Northern Ireland  2016  Extract  -

“The majority of people with disabilities are ambulant disable people”.

Premier League 2018 - Ticketing and Matchday Guidance – Extract

The ASG states that ‘in addition to the provision of wheelchair user accommodation all stadia should provide an equitable number of amenity and easy access seats for spectators who may require more space.’  The ASG suggests various criteria to consider in relation to amenity seating, such as access routes, the provision of arm and backrests, sightlines and additional legroom. It doesn’t contain an agreed definition for enhanced amenity seating or easy access seating and no design criteria or exact measures for seat location or distribution are included

Recommended changes:-

i)                    As disabled spectators may be unable to stand easily or change position comfortably, sufficient row depth should be provided to enable other spectators to move past the seated disabled spectator without the need to stand and be disturbed.

          Recommended row depth to be 1,000mm.   See diagram below.

ii)                  Because ambulant spectators are not always able to stand up, the seats allocated to them and that of their companion, must be located and designed in such a way that if spectators or other personnel, in front or on either side, stand up or walk in front of them the sightlines will not be obstructed.

To be included as a qualifying ambulant seat for calculating the minimum requirement under the Accessible Stadia Guidelines, both i) and ii) must be met.

Where an ambulant disabled supporter has provided evidence of their disability and confirmed that they require the support of a PA, provision should be made for the PA to be seated alongside.

Recommended dimensions to facilitate the non-disturbance of ambulant spectators – seat depth 400mm – distance from seat edge to forward barrier 600mm.  A minimum of 50% of ambulant seating must meet this specification, 75% to be elevated.

An Accessible Stadia Guideline qualifying “elevated” position is characterised by the raising of the disabled spectator to a height where their view is unobstructed.

Pitch side positions must be elevated where views are obstructed.  It is not acceptable to view between gaps in hoardings.

Passing movement in front of these positions should be minimised.

Where it is not practical to prevent frequent passage or stadium personnel stationed in front of these spectators, a walkway behind these seats should be considered.

It is important to consider that ambulant disabled people may often prefer to sit within the general seating areas rather than in designated accessible viewing areas. Therefore it is important to provide and identify areas in stadia which have level access and/or minimal steps, and are designed in accordance with the Recommended Standards below, including at the end of rows and/or close to exits. For matches this will include provisions for both home and away fans.

Handrail provision -  Provide hand or “P” rails where ever steps are encountered to comply with the recommendations 8.10 - Handrails for stairway and ramps.
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40m of accessible toilets

There should be an accessible toilet within 40m of any wheelchair position and amenity or easy access seating, with one accessible toilet provided for every 15 disabled spectator seats.

In addition to the minimum distance to an accessible toilet, the route to that toilet must also be considered, i.e. a route through a congested concourse may be a greater issue than distance as might passage through an area of opposing supporters.